The Solar Massachusetts Renewable Target Program, or SMART, is finally here and will officially launch on November 26th. Here at BlueWave, we certainly took a moment to celebrate the news. It’s been a long journey since 2016 and my colleagues at BlueWave and our partners at the Solar Energy Industry Association, the Solar Energy Business Association of New England, and the Northeast Clean Energy Council pushed hard to make the SMART program as robust as possible. We showed up in force at hearings, wrote letters to policymakers, and worked behind the scenes as stakeholders on the many phone calls and meetings held over the years.
At its core, the SMART program is an ambitious plan to nearly double solar capacity in Massachusetts and sets out to resolve several issues impacting community solar in the state, including solar bill credits, metering, and utility load zones. After reviewing the 219-page SMART order and convening with our industry colleagues, we’ve assembled some notes on where we think the SMART order succeeded, and where there are still areas of uncertainty.
Where we won
There are some major wins for the solar industry in the SMART order, and the alternative on-bill credit cap is chief among them. Here are some of the key components of the program that we’re particularly excited about:
- No caps on Alternative On-Bill Credit (AOBC): A cap on AOBCs would have negatively impacted low- and middle-income residents’ ability to see real value from participating in solar and would have further slowed solar growth in Massachusetts.
- Co-located Storage Not Included in Solar Tariff Generation Unit Definition: This is important because storage systems do not generate energy, so it was argued that they should not be treated as if they do.
- Massachusetts Department of Energy Resources (DOER) Program Enforcement: DOER is responsible for all determinations of non-compliance with the SMART Program and for determining whether the owner is removed from the Tariff. Since DOER is the author of the qualification guidelines and is responsible for processing applications, it makes sense that DOER would be the authority on non-compliance determinations.
- Credit Allocation Errors: The Department of Public Utilities (DPU) directs the utilities to start tracking errors in credit allocations. This is good news for many solar companies that have had issues with credit allocation errors for customers in the past. The DPU clearly understands what a big issue this is and is taking the appropriate action by directing the utilities to take these errors seriously.
Where there’s room for improvement
There are, without a doubt, some key elements missing from the SMART order. We pushed hard on these issues, but unfortunately, they didn’t come to fruition. Moving forward we will continue to work with our industry coalition partners to figure out new ways to address these issues.
- We, along with the Attorney General’s office, requested the ability to update credit allocations on a monthly basis. Instead, the DPU ordered that Payment/Credit Forms can be updated twice a year. However, changes to credit allocations often occur more than twice a year and billing should align with the reality of customer management.
- We hoped the DPU would direct the utilities to apply credits within one billing cycle, but the utilities are now required to apply credits within 3 billing periods from the completed Payment/Credit form. Unfortunately, this means customers cannot get an accurate picture of their credit allocation each month, which causes confusion. We hope that this will be addressed when the billing system is automated.
- We asked for the life of an incentive payment to be one year, the DPU determined that it should be 90 days. This is value that is owed to the projects and shouldn’t have a short expiration date.
Where clarity is still needed
Even though the SMART orders have been issued and the program is ready to launch in November, there are still several important components of the order that need clarity. Here’s what we’re working to clarify and what we’re looking forward to learning more about:
- Who can claim the capacity rights of storage? Utilities’ claim to storage capacity from solar facilities with co-located energy storage systems will be decided in the 17-146 order.
- Who can claim the capacity rights of AOBC Facilities and Qualifying Facilities? Utilities’ claim to the capacity rights of AOBC facilities and Qualifying Facilities will be decided in the 17-146 order.
- When will the utilities automate billing? The DPU did not direct the utilities to automate billing before the SMART program is rolled out, but the utilities will be required to submit details and timelines for moving toward automation in January, 2019.
- What about storage? The DPU required DOER to work with stakeholders to revise the storage guidelines. Current storage systems will be able to qualify under existing guidelines in the interim.
- What did the order say about the NSTAR and WMECo merger? Eversource will be considered one utility under the SMART Program, merging NSTAR in Eastern Massachusetts and WMECo in Western Massachusetts. As a result, DOER and the utilities will need to determine whether new SMART capacity blocks and base compensation rates will remain the same or change.
We’re thrilled to see SMART moving forward because, as we’ve said all along, it will jump-start the Massachusetts’ economy and will allow the Commonwealth to continue as a national leader in solar development and jobs.
As we draw closer to November 26th, there will be many discussions, presentations, and operational guidelines to help clarify points of confusion and launch the program successfully. DOER hosted several community events and a webinar in October to go over details for the launch of the SMART program, including a review of the SMART Application Portal. Presentation material can be found on DOER’s website.